Beyond the Jargon - A Blog by Calibra

Calibra Privacy Statement

Updated January 2015

Our Commitment to Your Privacy
Calibra is committed to respecting your privacy. Providing a secure environment in which you can participate in online activities is important to us. This Policy discloses our privacy practices and reflects our commitment to keeping you informed of the information we collect and how it is used. We encourage participants to review this policy periodically as it may be updated to encompass new rules, regulations and uses.

Safe Harbor
Calibra complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Calibra has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Calibra’s certification, please visit http://www.export.gov/safeharbor/.

Information Collection and Use
Calibra provides online 360 Degree Assessments as well as other types of organizational surveys. Participants in these assessments are employees of our client organizations. We typically collect the following information: participant and raters' names and email addresses. For the 360 Degree Assessments, we also collect the feedback ratings that are provided via the online process. Personally identifiable information provided to us by our clients, participants and raters is for purposes of conducting the assessment only, is treated as confidential information, and is not used for marketing purposes or divulged to third parties.

The primary use of the 360 Degree Assessment data is to produce an individual report for the participant that highlights their leadership strengths and development needs. At times the client organization chooses to have individuals other than the participant receive the report as well (e.g. HR staff, participant's manager, consultant). Calibra provides that information only when prior notice has been given to the participant.

The individual participant ratings are sometimes aggregated into a group report(s) for the client organization. When used in aggregate reports, individual results are not identifiable to the Participant.

Calibra uses e-mail in the delivery of assessment services. We do not provide participant or respondent e-mail addresses to third parties or use them for marketing purposes.

Notice
As noted above, participant and rater data (name and email address) is provided by the client organization and/or the participant. Participants are informed about the purpose and use of the information with the assessment notification and have access to this privacy policy via the Calibra website. They are also provided Calibra contact information should they have questions or concerns.

The data is never used for purposes other than that for which it was originally collected.

Choice
Since individual data is never used outside of the purpose stated above nor is disclosed to a third party outside of the client organization, there is no "opt out" choice required. Should an individual not want to participate in the assessment, that is a matter between that person and the client organization (their employer).

Onward Transfer
Should data ever need to be transferred to a third party, Calibra adheres to the Notice and Choice principles outlined above.

Data Security
Calibra takes precautions to protect our participants' information both online and off-line. Participant information is stored on servers in a locked, secure environment. These servers are protected from hackers with firewalls and a variety of other security mechanisms and procedures. Only our employees or contractors who perform programming, server maintenance and security support or designated administrators in client organizations have access to this information. All employees and contractors with access to the information comply with our privacy practices.

We use Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive data. SSL encryption is designed to make the information unreadable by anyone but us. This security measure is working when you see either the symbol of an unbroken key or closed lock (depending on your browser) on the bottom of your browser window.

Data Integrity
Calibra will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the participant.

Access
Assessment participants have access to the personal information collected by Calibra via a link to a personalized dashboard. They can access this page at any time through a direct link emailed to them and through a password protected logon. Participants can correct inaccurate information by contacting an identified administrator inside the client organization or by contacting Calibra directly via email or phone as noted on their personal webpage.

Enforcement
Any questions or concerns regarding the use or disclosure of personal information should be directed to Calibra, 2810 Crossroads Drive, Suite 4000, Madison, WI 53718. Calibra will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

If a complaint or dispute cannot be remedied by Calibra, and it concerns personal information sent from an EU member country to the United States, Calibra has agreed to resolve such complaint or dispute in accordance with the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Principles. Similarly, Calibra has agreed to cooperate and comply with the Swiss Federal Data Protection and Information Commissioner with regard to personal information sent from Switzerland to the United States.

Links
Calibra resources pages and website contains links to other sites. Please be aware that Calibra is not responsible for the privacy practices of such other sites. We encourage our participants to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by Calibra.

Notification of Changes
Any changes to our privacy policy will be posted to this privacy statement on our homepage and other places we deem appropriate. Our users will always be aware of what information we collect, how we use it, and under what circumstances we disclose it. We will use information in accordance with the privacy policy under which the information was collected.